Data Processing Addendum

• For End User data — data sent by the installers of your apps (section 2) — you are the controller and Ivorn is your processor.
• For your account, workspace and billing data, Ivorn is an independent controller, as described in the Privacy Policy. This DPA does not apply to that data.

Ivorn will:

• process End User data only on your documented instructions — these Terms, this DPA and your configuration ofOmnihorn — unless the law requires otherwise, in which case Ivorn will tell you first where the law allows;
• ensure that everyone authorised to process the data is bound by confidentiality;
• implement the security measures in section 7;
• engage subprocessors only as described in section 5;
• help you, taking into account the nature of the processing, to respond to End Users exercising their rights and to meet your obligations on security, breach notification, impact assessments and prior consultation;
• notify you of a personal data breach as described in section 6;
• delete or return End User data at the end of the service, as described in section 8;
• make available the information needed to demonstrate compliance with this DPA, as described in section 9.

You are responsible for having a lawful basis for the processing, for informing your End Users (for example in your application’s privacy notice) and for the lawfulness of your instructions.

You authorise Ivorn to use the subprocessors below. Ivorn imposes data-protection obligations on each of them that are no less protective than this DPA, and remains responsible for their performance.

Current subprocessors

Planned — will be added before launch

These providers are not used today. They will be added when the corresponding change goes live, with notice as described below.

Changes. Ivorn will update this list and notify customers by email or in the dashboard at least [[PLACEHOLDER: subprocessor change notice period — e.g. 30 days]] before a new subprocessor starts processing End User data. You may object on reasonable data-protection grounds by writing to privacy@unicornfamily.dev within that period; if we cannot address the objection, you may cancel the affected service and receive a pro-rata refund of prepaid fees for it.

Ivorn will notify you without undue delay, and in any case within [[PLACEHOLDER: breach notification window — e.g. 72 hours]], after becoming aware of a personal data breach affecting End User data. The notice will describe the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed. Where not all of this is available at once, Ivorn will provide it in phases.

The technical and organisational measures in place today are:

• TLS for all public traffic to the dashboard, API and update service.
• Every build manifest signed with a per-app Ed25519 key and verified by the installer before any file is applied; each downloaded file verified against its SHA-256 hash.
• App signing keys encrypted at rest with a master key, or optionally held under a cloud key-management service.
• Channel tokens and API keys stored only as SHA-256 hashes; private channels can also require a password, stored as an argon2id hash.
• Per-workspace isolation: every query is scoped to the workspace, and a workspace can only reference stored files it uploaded itself; download links are short-lived and signed.
• The update service reads only the application database; account and billing data sit in a separate database it cannot reach.
• Staff accounts use argon2id-hashed passwords with lock-out after repeated failures, separate credentials from customer accounts, role-based permissions and an audit log of every administrative action. The administration site is reachable only over a private network.
• Uploads may be scanned for malware before they are published.

Ivorn may improve these measures over time but will not materially reduce the overall level of protection.

At the end of the service, or earlier on your written request to privacy@unicornfamily.dev, Ivorn deletes the End User data it holds for you from its active systems, unless the law requires it to keep it. Deleting an app in the dashboard deactivates it but does not yet purge its End User data automatically, and automatic retention schedules for analytics events and access logs have not been introduced; until they are, that data is kept until it is deleted on request or the account is closed. Copies in logs are removed as those logs are rotated.

On written request, not more than once a year unless a breach or a supervisory authority requires more, Ivornwill answer reasonable written questions about its compliance with this DPA and provide relevant documentation. Any on-site audit must be agreed in advance, at your cost, and subject to confidentiality.

Ivorn operates from Ukraine, and subprocessors may process data in the European Union, the United Kingdom and the United States. Where End User data from the EEA, the UK or Switzerland is transferred to a country without an adequacy decision, the parties rely on [[PLACEHOLDER: SCC module/version and transfer mechanism]], which are incorporated into this DPA by reference, with Ivorn as data importer.

Liability under this DPA is subject to the limitations in the Terms of Service. If this DPA conflicts with the Terms on the processing of End User data, this DPA prevails; the standard contractual clauses, where they apply, prevail over both.